Real estate situated in Germany
Rental and sale of real estate situated in Germany: Income from
rental of real estate located in Germany is subject to non-resi-
dent tax liability. The same applies to income from the sale of
real estate located in Germany.
As a rule, the rental of real estate does not give
rise to the formation of a permanent establish-
ment. It has been practice under tax treaty law in Germany to
allocate the right to tax income from the rental of real estate and
gains arising from the sale of real estate, in most cases, to the
country in which the property is situated, i. E. Germany.